New York Court of Appeals
Jon Holt v. Board of Education of the Webutuck Central School District, Respondents In the Matter of Wayne Doyle v…
May 7, 198152 N.Y.2d 625
Summary
The Court held that written critical evaluations placed in a teacher's permanent personnel file are administrative evaluations, not disciplinary reprimands, and therefore are not subject to the hearing requirements of section 3020-a of the Education Law. Accordingly, the Court affirmed the Appellate Division's dismissal of Holt's petition and reversed the Appellate Division's reversal of Doyle's dismissal. Chief Judge Cooke dissented, arguing the letters are disciplinary and require §3020‑a protections, while Judge Wachtler concurred in part and dissented in part, distinguishing the letters in Holt's case from those in Doyle's.